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N.D. Cal.Procedural orderFiled Aug. 17, 2023

Howard v. Hain Celestial Group, Inc.

Judge
Vince Chhabria
Docket
3:22-cv-00527
Court
U.S. District Court · Northern District of California
Pages
1
Civil ProcedureMotion to Dismiss
In one sentence

In Howard v. Hain Celestial Group, Judge Chhabria denied partial reconsideration because it would not affect plaintiffs’ ability to pursue fraud-based claims.

Who this affects

The ruling concerns the plaintiffs’ fraud-based claims against Hain Celestial Group, Inc.; the court said reconsideration would not affect the plaintiffs’ ability to pursue those claims.

What happened

In Howard v. Hain Celestial Group, Inc., the court considered a request to partially reconsider an earlier decision involving Hain Celestial’s motion to dismiss the plaintiffs’ fraud-based claims.

The court said an earlier decision suggested it had used the wrong legal standard when evaluating that motion. But reconsideration would not change the plaintiffs’ ability to pursue their claims and would only cause delay. The court also said a Ninth Circuit decision did not apply because the products’ intended use for children under age two was not ambiguous based on the complaint’s allegations.

Judge Vince Chhabria denied the motion for partial reconsideration. The ruling did not remove the plaintiffs’ ability to pursue the fraud-based claims.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Howard v. Hain Celestial Group, Inc. · No. 3:22-cv-00527
Judge
Vince Chhabria
Date
Aug. 17, 2023

Background

The plaintiffs brought fraud-based claims in their first amended complaint against Hain Celestial Group, Inc. Hain Celestial had previously moved to dismiss those claims. The opinion concerns a motion for partial reconsideration of the court’s earlier decision.

Court’s Analysis

The court stated that its decision in an earlier related case suggested it had applied the wrong legal standard when evaluating Hain Celestial’s motion to dismiss. Even so, the court concluded that reconsideration would not affect the plaintiffs’ ability to pursue the fraud-based claims and would only create delay.

The court also rejected reliance on the Ninth Circuit’s decision in McGinity v. Procter & Gamble Co. The court said that, accepting the complaint’s allegations as true, it was not ambiguous whether products marketed as “toddler” foods or for children ages “9+ months” were intended for children under age two.

Disposition

Judge Vince Chhabria denied the motion for partial reconsideration. The opinion does not state which party filed that motion.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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